Before and After 2021: How the EU’s Distance Selling Rules Changed

 

 

Bevezetés

If you sold goods online to customers in Europe before the summer of 2021, you probably remember how forgiving the system felt. A parcel worth twenty euros leaving a factory in Shenzhen could land on a doorstep in Lyon or Leipzig with no import VAT, a thin customs declaration and very little paperwork. Sellers established inside the European Union, meanwhile, were busy registering for VAT in one member state after another as their cross-border sales crept over a patchwork of national thresholds. The playing field was uneven, and everyone in the industry knew it.

On 1 July 2021 the EU rewired that system. The VAT e-commerce package scrapped the old distance selling thresholds, ended the import VAT exemption for consignments up to €22, introduced the One Stop Shop (OSS) and the Import One Stop Shop (IOSS), and made online marketplaces responsible for collecting VAT on a large share of cross-border sales. For freight forwarders, customs brokers and the sellers who depend on them, it was the biggest change to European e-commerce logistics in a generation.

The story did not end in 2021. In 2026 the Union turned to the other half of the problem, the €150 customs duty exemption. A temporary flat duty of €3 per item has applied since 1 July 2026, and a €2 handling fee is expected to follow on 1 November 2026. This article walks through the rules before and after 2021, explains how each shipping model works today, compares the numbers, covers what has changed this year, and shows how freight and fulfilment decisions should adapt. It is written for sellers, forwarders and operations teams who need practical answers rather than legal theory.

The Rules Before July 2021: A System Built for Mail Order

Before 2021, the EU treated distance sales, meaning business-to-consumer sales of goods shipped from one place to a buyer in another, with rules designed for the catalogue era. Two separate regimes mattered, one for trade inside the EU and one for goods arriving from outside it. Both were stretched far beyond what their designers had imagined, and understanding why they failed is the quickest way to understand why the reform looks the way it does.

Distance selling thresholds inside the EU

Under the old model, a business established in one member state charged its otthon VAT on sales to consumers elsewhere in the Union until its annual sales into a particular destination country crossed that country’s distance selling threshold. Each member state chose either €35,000 or €100,000, so a seller could sit comfortably under the limit in Germany and already be over it in France. Once the line was crossed, the seller had to register for VAT in the destination country, file local returns, charge the local rate and often appoint a fiscal representative.

For a growing online store this meant five, ten or even fifteen VAT registrations, each with its own filing calendar, language and local quirks. Many small sellers simply avoided certain markets or ignored the rules until an audit arrived. The compliance burden fell hardest on exactly the businesses the single market was supposed to help.

The €22 import VAT exemption

The second regime covered goods coming from outside the EU. Member states were allowed to exempt consignments with a value of up to €22 from import VAT. The idea was reasonable when it was written: collecting a euro or two of tax on a birthday gift cost more than the tax was worth. By the late 2010s, however, the exemption had turned into a business model. Sellers in Asia could ship a €20 item straight to a consumer in France or Italy, declare it under the limit, and the buyer paid no VAT at all.

A retailer in Rotterdam selling the identical item had to add 21% Dutch VAT to the price, which made fair competition impossible. Customs authorities also reported widespread undervaluation, with higher-priced goods declared below the line and orders split into several smaller parcels. Because the exemption applied to the consignment rather than to the sale, it was easy to game and hard to police.

The separate €150 customs duty relief

Customs duty followed a different track. Under Council Regulation (EC) No 1186/2009, goods in consignments with an intrinsic value of up to €150 were free of customs duty. That relief was not touched in 2021, and it is worth remembering because it returns to the story later in this article. In 2021 the EU fixed the VAT side of the problem while leaving the duty side alone, which is why many forwarders describe the 2021 package and the 2026 measures as two halves of one reform.

By 2020 the volume of low-value parcels had grown from a trickle into billions per year, almost all of them arriving through postal and express channels with minimal data. Customs offices could not realistically inspect them, tax authorities could not reconcile them and domestic retailers could not compete with them.

July 1, 2021: What Actually Changed

The e-commerce VAT package, adopted under Council Directive (EU) 2017/2455 and Directive (EU) 2019/1995, applied from 1 July 2021 after a delay caused by the pandemic. It touched five areas at once, and each one affects freight planning differently.

One EU-wide threshold of €10,000 and the One Stop Shop

The country-by-country thresholds of €35,000 and €100,000 disappeared. In their place came a single EU-wide threshold of €10,000 per year covering intra-EU distance sales of goods and certain cross-border services. The threshold applies only to businesses established in a single member state. Once cumulative sales to consumers in other member states exceed €10,000, the seller must charge VAT at the rate of each customer’s country.

To avoid the registration maze of the past, the Union OSS lets a seller register once, in its home member state, and report all cross-border B2C sales in a single quarterly return. The return is filed in the home country and payment is due by the end of the month following the quarter. The home tax authority then distributes the money to the destination countries. Records must be kept for ten years, which surprises many small sellers.

The end of the €22 exemption and the arrival of IOSS

The import VAT exemption for low-value consignments was abolished entirely. From 1 July 2021, VAT applies to every imported good regardless of value. To keep small parcels flowing without a border collection for each one, the EU created the Import One Stop Shop for consignments with an intrinsic value of up to €150.

Under IOSS, the seller or the marketplace charges the destination country’s VAT at the point of sale, so the consumer sees a final price at checkout. The seller then reports and pays that VAT in a monthly IOSS return, due by the end of the following month, in one member state. At the border, the parcel is cleared with the seller’s IOSS number on the declaration and no further VAT is collected from the consumer. A non-EU seller normally needs an EU-based intermediary to register, unless it is established in a country with a VAT mutual assistance agreement with the EU, such as Norway or the United Kingdom. Goods subject to excise duty, such as alcohol and tobacco, cannot use IOSS.

Marketplaces as deemed suppliers

The package also changed who is legally treated as the seller. When an electronic interface, such as a marketplace, facilitates the distance sale of imported goods worth up to €150, or the sale of goods already in the EU by a non-EU seller, it is deemed to have received and supplied the goods itself. In plain terms, the platform becomes responsible for collecting and remitting the VAT.

This shift moved a great deal of VAT compliance from thousands of small overseas sellers to a few large platforms, which is exactly what the Commission wanted. For forwarders it means the party that gives you the IOSS number and the shipping instructions is often a platform rather than the manufacturer, and data flows need to match accordingly.

The special arrangement and the H7 declaration for non-IOSS parcels

Not every seller uses IOSS. For parcels worth up to €150 that arrive without an IOSS number, the EU created a special arrangement. The person presenting the goods to customs, often a postal operator or express carrier, collects the VAT from the consumer at delivery and pays it over to the tax authority monthly. These shipments can be cleared with the reduced H7 customs data set, which carries far fewer data fields than a full import declaration.

The special arrangement works, but it is slower and creates friction for the buyer, who may face a payment request or an administrative fee at the door. Carriers often add handling charges, and refusal rates tend to be higher. That is why most serious B2C exporters moved to IOSS, or to bulk import with local fulfilment, shortly after the reform.

Table 1: The distance selling rules before and after 2021

Téma	2021. július 1. előtt	2021. július 1. után
Intra-EU distance selling threshold	€35,000 or €100,000, set by each destination country	One EU-wide threshold of €10,000 for micro-businesses
VAT registration for cross-border B2C	Separate VAT registration in each country over the threshold	One registration and one return through the Union OSS
Import VAT on low-value goods	Exempt up to €22 (member state option)	No exemption; VAT due on all imports
Scheme for goods up to €150	None; the consumer usually paid nothing	IOSS, or the special arrangement with the H7 data set
Marketplace responsibility	Generally none for VAT collection	Deemed supplier for imports up to €150 and for non-EU sellers with EU stock
Customs duty relief	Duty-free up to €150	Unchanged in 2021; changed in 2026
Nyilvántartás	Varied by country	Ten years for OSS and IOSS records

 

How the Main Shipping Models Work Under the Current System

The reform did not simply change tax rates; it changed which logistics models make financial sense. A seller who once picked a carrier on price alone now has to decide how VAT will be collected, who will be named as importer and how much data the shipment will carry. In practice, four models dominate European e-commerce flows from Asia, and the table below shows how they compare.

Table 2: Common shipping models for B2C sales into the EU

Modell	Érték:	Who handles VAT	Customs document	A legalkalmasabb
Direct parcel with IOSS	Akár € 150	Seller or marketplace at checkout	H7 with IOSS number	Low-value, high-volume DTC
Direct parcel without IOSS	Akár € 150	Collected at delivery under special arrangement	H7 data set	Occasional or test shipments
Direct parcel above €150	150 euró felett	Importer at the border, buyer or seller	Full H1 declaration	Higher-value goods, DDP or DAP
Bulk shipment to EU warehouse	Bármilyen	Seller imports once, then OSS for cross-border sales	Full H1 declaration for the bulk entry	Repeat sellers, fast delivery, easy returns

 

Direct parcels with IOSS are the closest descendants of the old mail-order model. They suit lightweight, low-value goods, where the shipping cost per item is low and the customer expects a short checkout journey. The weak points are transit time, because parcels often rely on air or postal channels, and returns, which are difficult and expensive when the goods must travel back to Asia.

Above €150, the old rules never really applied. Goods go through a full import declaration with the proper tariff classification, duty and import VAT, and somebody has to be named as the importer. If the buyer is the importer, the parcel can be delayed, refused or abandoned. If the seller takes the role under a delivered duty paid arrangement, the seller must be able to register and pay in the destination country, which usually means a local VAT number and often a customs representative.

The fourth model, shipping goods in bulk to a warehouse inside the EU, has gained the most from the 2021 rules. A seller can move a full container by sea, clear it once as a standard import, recover the import VAT through its VAT registration, and then dispatch orders domestically or across borders using the Union OSS. Because the cargo travels as a consolidated shipment, the freight cost per item drops sharply and the consumer receives a parcel delivered by a local carrier in a day or two.

What Has Changed Since: The 2026 Duty and Fee Reforms

The 2021 package closed the VAT gap but left the customs duty exemption in place, so goods under €150 still crossed the border without duty. That is now ending. The Council formally agreed the change on 11 February 2026 in Regulation (EU) 2026/382, which amends Regulation (EC) No 1186/2009 and removes the value-based duty relief.

The €3 flat duty

From 1 July 2026 until 1 July 2028, a flat customs duty of €3 per item applies to goods in distance-sale consignments with an intrinsic value of up to €150, in particular those cleared under IOSS or carried by postal services. It is a temporary bridge. The EU plans to launch a central Customs Data Hub around 2028, after which all goods below €150 are expected to face the normal tariff for their classification, just like higher-value imports today.

The word item matters a great deal. The duty is applied per tariff line, meaning goods in a consignment that share the same tariff classification are treated as one item, while goods with different classifications are charged separately. A parcel with a phone case, a charging cable and a pair of socks could therefore attract €9 in duty even though its total value is small. Accurate product descriptions and correct HS codes have gone from good practice to a direct cost driver.

Import VAT works as before, but the €3 duty is added to the taxable value, so the consumer pays VAT on the duty as well. Non-commercial gifts between private individuals remain outside the new duty in most member states, although the details are set nationally.

The €2 handling fee

A second charge is on its way. On 21 September 2026 the European Commission adopted a delegated act setting the Union handling fee at €2 per item, based on the new Union Customs Code, Regulation (EU) 2026/2108. The fee covers customs processing of distance-sale goods and is distinct from the €3 duty. It is expected to apply from 1 November 2026, subject to the end of the scrutiny period and publication in the Official Journal, so sellers should check the final text before updating prices.

The new Code also changes liability. For online sales, responsibility for the customs side passes to the operator who sells or facilitates the distance sale, which brings large platforms firmly into the picture. From July 2028, a lower fee is planned for goods released from customs warehouses for distance sales, which signals where policymakers want the market to go: toward stock held inside the EU.

National charges in the meantime

Several member states did not wait for Brussels. Romania introduced a national charge of RON 25 per parcel on low-value non-EU shipments from 1 January 2026. France applied a €2 customs administration fee per declaration line between 1 March and 30 June 2026 and suspended it when the EU duty began. Italy legislated a €2 per-shipment contribution, which has been postponed several times and is now reported to start on 1 December 2026, leaving a risk of overlap with the EU fee. Austria is reported to be introducing a per-parcel levy on large operators from 1 October 2026. These national rules change quickly, so any seller shipping to those countries should confirm the position at the time of dispatch.

Table 3: Timeline of the main reforms

találka	Mérték	Kulcsfontosságú pont
1 July 2021	EU VAT e-commerce package	OSS, IOSS, €10,000 threshold, end of €22 exemption, deemed supplier rules
1 2026 Jan	Romania national parcel charge	RON 25 per low-value non-EU parcel
11 február 2026	Regulation (EU) 2026/382 adopted	Legal basis for removing the €150 duty relief
1 July 2026	Flat €3 duty per item	Applies to consignments up to €150 until 1 July 2028
21 2026 szeptember	Delegated act on handling fee	Sets the Union handling fee at €2 per item
1 Nov 2026 (expected)	Union handling fee	Subject to scrutiny and Official Journal publication
1 July 2028	End of interim regime	Customs Data Hub and normal tariffs expected for goods under €150

 

What it costs in practice

A simple illustration shows how the layers add up. The figures below assume a destination VAT rate of 21%, a single tariff line in the first example and three tariff lines in the second, and they leave out shipping cost and any national fees. They are not a substitute for a customs calculation, but they show the direction of travel.

Table 4: Illustrative import charges on low-value parcels (VAT rate 21%)

Forgatókönyv	Adó	áfa 21%	Kezelési költség	Teljes díj
€40 parcel, one tariff line, before July 2026	€0.00	€8.40	€0.00	€8.40
€40 parcel, one tariff line, from July 2026	€3.00	€9.03	€0.00	€12.03
€40 parcel, one tariff line, with the expected fee	€3.00	€9.03	€2.00	€14.03
€90 parcel, three tariff lines, before July 2026	€0.00	€18.90	€0.00	€18.90
€90 parcel, three tariff lines, from July 2026	€9.00	€20.79	€0.00	€29.79
€90 parcel, three tariff lines, with the expected fee	€9.00	€20.79	€6.00	€35.79

 

The pattern is clear. A €40 item sees its tax and fee burden rise by roughly two thirds once both measures apply, and mixed parcels suffer much more because each tariff line is charged separately. A seller that used to rely on the price advantage of duty-free small parcels will find that margin shrinking, and the shrinkage is largest for multi-item orders with varied contents.

What This Means for Freight Forwarders and Sellers

Taken together, the 2021 and 2026 changes point in one direction. The EU wants low-value goods to enter through formal, data-rich, tax-paid channels, and it is making informal channels progressively more expensive. The practical consequences differ for each type of business, but a few themes apply almost everywhere.

Rethinking direct parcels versus bulk freight

When duty and handling fees are charged per item, a parcel containing several different products becomes costly, while the same goods imported in bulk are cleared once and taxed according to the standard tariff and the value of the whole shipment. The more varied the basket, the stronger the argument for importing stock in bulk and fulfilling from inside the EU.

Ocean freight is the natural vehicle for that strategy. Less-than-container-load shipments let smaller sellers consolidate with others, while full-container-load shipments suit sellers whose volumes justify a dedicated box. Both bring the per-unit freight cost far below that of air parcels, and both turn the customs event into a single, properly documented import. The trade-off is working capital: stock sits in a warehouse and demand must be forecast, so the model fits products with predictable turnover better than one-off novelties.

Data quality has become a cost line

Before 2021, a vague description such as gift or sample often went unnoticed. Today, the HS code drives the number of items charged, and the declared value drives both VAT and the €150 boundary. Sellers should align product catalogues with customs descriptions, keep consistent HS codes for each SKU and make sure the commercial invoice, the IOSS number and the order data tell the same story.

The same applies to security filings. The EU’s Import Control System 2 has been rolled out in stages since 2021 and now covers ocean, road and rail as well as air and postal flows, which means advance cargo data must be filed before goods are loaded or arrive. Late or inaccurate data can cause holds long before the parcel reaches a customs officer.

Returns, refusals and unpaid VAT

Distance sales into the EU are subject to the Consumer Rights Directive, which gives buyers a 14-day right to withdraw from the contract. A buyer who returns a parcel shipped under IOSS will expect a refund of the VAT paid, and sellers must adjust their IOSS returns accordingly. The flat duty and the handling fee, on the other hand, are generally not refundable in the same way, so they should be factored into return policies and margins from the outset.

Refusals are a particular headache in the non-IOSS special arrangement, where the buyer is asked to pay on delivery. A refused parcel generates return freight, lost goods and sometimes a customs formality in both directions. Switching the same volume to IOSS or to local stock removes most of that risk.

Product compliance sits next to tax compliance

The EU has not only tightened tax rules. The General Product Safety Regulation has applied since December 2024 and requires products sold to EU consumers to have a responsible economic operator in the Union, along with traceability information. Enforcement bodies increasingly use customs data to target non-compliant online goods. A forwarder who can match the shipment with the right documents helps the seller avoid seizures that no tax scheme can fix.

A Practical Compliance Playbook

Reading the rules is the easy part; building a workable process is harder. The approach below is the one we see working for sellers that ship regularly into the EU, from first-time exporters to established brands. It is general information rather than tax advice, and rates, thresholds and national fees can change, so confirm the current position with a qualified adviser before relying on any of it.

Start with the sales model, not the carrier

Decide first whether the business will sell mostly through marketplaces, its own website or both. Marketplace sales into the EU often arrive with the platform already acting as deemed supplier and providing an IOSS number, while sales through your own store place the VAT collection duty on you. That single decision shapes registrations, pricing at checkout and the data your forwarder needs.

Choose registrations that match the flow

A seller shipping direct parcels under €150 should look at IOSS and appoint an intermediary if required. A seller who holds stock in an EU warehouse will need a VAT registration in the warehouse country, may use the Union OSS for sales into other member states, and must still deal with domestic VAT in the warehouse country. A micro-business established in one member state and shipping only within the EU may be able to stay under the €10,000 threshold and keep charging home-country VAT. These are different tax positions with different deadlines, and it pays to map them before the first shipment.

Price for the full landed cost

With €3 per item already in force and €2 more expected, the cost of low-value parcels has become less predictable than before. Decide whether to show duties and fees at checkout or build them into the price, and recalculate margins for multi-item baskets separately from single-item orders. Bundled products that share a tariff classification are cheaper to import than mixed bundles, which is worth considering in packaging and assortment design.

Build documentation habits early

Keep commercial invoices, packing lists, HS code decisions, IOSS or OSS records and proof of delivery for at least the period required, which is ten years for the OSS schemes. Tax audits tend to arrive years after the sale, and the evidence that is easy to produce on the day of shipping becomes difficult to reconstruct later.

How Topway Shipping Supports EU-Bound E-Commerce Flows

Topway Shipping has been a professional provider of cross-border e-commerce logistics solutions since 2010, from its headquarters in Shenzhen, China. The founding team brings more than 15 years of experience in international logistics and customs clearance, with a strong background in China to U.S. transportation, one of the most demanding trade lanes in the world for documentation and compliance. That experience transfers directly to Europe, where the same discipline around data, classification and timing now determines how smoothly goods move.

The services cover the whole logistics chain: first-leg transportation from the factory or consolidation point, overseas raktározás, customs clearance and last-mile delivery. For sellers adapting to the post-2021 and 2026 rules, that end-to-end structure is valuable because the questions are connected. The way a shipment is booked in China affects the declaration, the declaration affects tax and duty, and the warehouse model affects delivery speed and returns.

Topway also offers flexible full-container-load and less-than-container-load ocean freight from China to major ports worldwide, including the large European gateways that serve the continent’s e-commerce fulfilment networks. This matters in an environment where per-item duty and handling fees make bulk import more attractive. An LCL booking allows a smaller seller to consolidate stock into a single customs entry and move it to an EU warehouse at a far lower per-unit freight cost than air parcels, while an FCL booking gives larger sellers a dedicated container and a more predictable schedule.

In practical terms, a seller can work with Topway to compare direct parcel shipping with a bulk-to-warehouse model, prepare consistent product data and HS codes for customs, coordinate clearance and plan last-mile delivery from stock held closer to the customer. VAT registration and filing decisions should still be made with a tax adviser or intermediary, and Topway’s role is to ensure the physical and documentary flow matches whichever tax structure the seller has chosen.

Összegzés

The distance selling rules before 2021 rewarded the shortest route and the thinnest paperwork. A shared EU threshold, a single registration for cross-border B2C sales, a VAT scheme for imports and a deemed supplier role for marketplaces replaced them on 1 July 2021, and the 2026 measures have now brought customs duty into the same logic. The €3 duty per item is already in force, the €2 handling fee is expected on 1 November 2026, and the interim regime is due to give way to normal tariffs when the customs data hub arrives in 2028.

The lesson for sellers and forwarders is consistent. Low-value parcels still have a place, but the era of invisible small shipments is over. The winners will be those who choose a tax model on purpose, keep their product data clean, think carefully about bulk freight into EU stock and work with logistics partners that can handle the whole chain. If you are reviewing your European supply chain this quarter, now is a good time to compare the true landed cost of parcels against a bulk import model, and Topway Shipping can help you run that comparison.

GYIK

Q: What replaced the €22 import VAT exemption?

A: Nothing replaced it directly. VAT now applies to all imported goods from the first euro. For consignments up to €150, sellers can use IOSS to charge VAT at checkout, or the special arrangement, where VAT is collected on delivery.

Q: Do I need IOSS if I ship my goods in bulk to an EU warehouse?

A: Usually not, because IOSS covers distance sales of imported goods in consignments up to €150. Bulk imports are cleared with a standard declaration, and cross-border sales from the warehouse are typically reported through the Union OSS.

K: A 3 eurós vámot csomagonként vagy tételenként számítják fel?

A: It is charged per item, where an item means goods sharing the same tariff classification. A parcel with three differently classified products attracts €9, not €3.

Q: Is the €2 handling fee already in force?

A: Not as of 8 October 2026. The Commission has set it at €2 per item and it is expected to apply from 1 November 2026, subject to publication in the Official Journal, so check the final text.

Q: Does the €10,000 threshold apply to non-EU sellers?

A: No. It is limited to businesses established in a single EU member state. Sellers shipping from outside the EU generally use IOSS for low-value parcels or register for VAT in the EU country where their stock is held.